When it comes to websites, YouTube is one of the biggest beasts there is. With more than a billion users watching an estimated 5 billion videos everyday ranging from beauty tutorials to cooking demonstrations to gaming walk-throughs, it has something for everyone.
Little surprise then that it is an overwhelmingly popular online destination with children. According to Ofcom data eight in ten of all children aged 5-15 (81%) report using the platform (rising to 99% of 12 to 15 year olds). Due to its size and reach, YouTube is also a key part of a brand’s advertising strategy with Kelloggs recently reporting funnelling 70% of its advertising budget to YouTube due to the return on investment.
This week the Advertising Standards Authority (ASA) has chosen not to uphold a complaint we made about a Doritos advert that was shown before a gaming video watched by an under 16 on YouTube. One of the reasons ASA gave for not upholding the complaint was that data suggests that overall 90% of YouTube’s users are aged over 17, therefore ASA considered that under-16s do not make up a disproportionately high percentage of the platform’s users. However, we know that 59% of boys aged 8-11 say they watch computer game related content on YouTube.
This ruling shows the issues with the application of the Committee on Advertising Practice Code’s 25% threshold rule to very popular platforms such as YouTube. Due to its huge universal appeal, the proportion of adults using it will always outweigh the proportion of children using it. However, given the majority of UK children report using the site, millions of children will also be using YouTube.
A further reason ASA gave for not upholding the complaint was that Walkers took some steps to try and prevent their advert from being seen by children using YouTube’s built in audience targeting tools. However, they did not use all the tools available to them, e.g. they did not exclude the advert from appearing alongside adverts rated as “Suitable for younger teens” or “Suitable for teens”. In addition, they did not exclude the advert from appearing along videos in subject categories known to be popular with children on YouTube such as gaming. Instead they just excluded subject categories likely to be popular with much younger children such as ‘drawing and colouring.’
Walkers were not asked to provide data to show that the either the video the advert appeared before, or the channel the video was shown on was likely to have an audience comprised of fewer than 25% under 16s – despite it being a bespoke gaming channel which is popular with children.
The precedent set by this ruling shows how low the bar is set when it comes to protecting children from junk food adverts online. All HFSS brands have to show is that they have taken some potentially tokenistic steps to not target children directly. This does not sufficiently protect children from being exposed to junk food adverts.
This ruling highlights the total inadequacy of the existing rules in protecting children from seeing junk food adverts online, particularly on websites popular with both children and adults. This is the same issue as junk food adverts being shown during family viewing time on TV and is why the Government has committed to consulting on a 9pm watershed with similar restrictions applied online. Until this is brought in, responsible food brands should use all tools available to ensure children are not exposed to junk food adverts.